IR 05000275/1982020

IE Insp Repts 50-275/82-20 & 50-323/82-10 on 820506-28.No Noncompliance Noted.Major Areas Inspected:Implementation of Independent Verification Program Including Independence & Qualification of Personnel & Exam of QA Programs

ML20055A136
Person / Time
Site:	Diablo Canyon
Issue date:	06/28/1982
From:	Bishop T, Eckhardt J, Fair J, Herring K, Morrill P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20055A127	List: IR 05000275/1982020 ML20055A126
References
50-275-82-20, 50-323-82-10, NUDOCS 8207150509
Download: ML20055A136 (7)

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. U.S. NUCLEAR REGULATORY C0mlSSION

REGION V

Report No. 50-275/82-20 and 50-323/82-10 Docket Nos. 50-275 and 50-323 License Nos. DPR-76 and CPPR-69 Licensee: Pacific Gas and Electric Company P. O. Box 7442 San Francisco, California 94120 Facility Name: Diablo Canyon Nuclear Power Plant Inspection Location and Date(s): (1) Teledyne Engineering Services West Coast Office, Hayward, California - May 6, 1982 (2) Pacific Gas and Electric Company, Diablo Canyon Site, Avila Beach, California - May 10-11, 1982 (3) Pacific Gas and Electric Company Corporate Offices, San Francisco, California - May 12-15, 1982 and May 26-28, 1982 (4) R. L. Cloud and Associates, Berkeley, California -

May 13, 1982 (5) Teledyne Engineering Services, Waltham, Massachusetts -

May 25-26, 1982 Report by: h/ for 4/38/85

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T. W. Bishop, Chief Date Reactor Construction Projects Branch Summary:

Inspection _during period of May 6-28, 1982 (Report Nos. 50-275/82-20 and 50-323/82-10)

The inspectors examined the following areas: (1) Implementation of the Independent Verification Program including independence and qualification of personnel, review of independent calculations, examination of Quality Assurance programs and Project Procedures, examination of log files and discussions with personnel; and (2) Pacific Gas and Electric Company Technical Program efforts including an examination of field modifications, a review of Civil and Mechanical engineering procedures, as well as an examination of The Blume Internal Reviews and discussions with personnel. This inspection effort involved 112 inspector-hours by four NRC inspectors and 72 reviewer 8207150 EON 629 e NRC Headquarters personne PDR ADOCK 05000275 0 PDR

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DETAILS

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1. Persons Contacted Pacific Gas and Electric Company J. B. Hoch, Project Manager B. S. Lew, Licensing Engineer R. R. Fray, Verification Program Coordinator M. R. Tresler, Mechanical / Piping Group Supervisor G. H. Moore, Project Engineer, Unit No. 1 i Bechtel Power Corporation H. B. Friend, Project Completion Manager R. C. Anderson, Engineering Manager W. White, Assistant Project Eegineer, Seismic J. K. McCall, Civil Group Supervisor R. L. Cloud and Associates i

l R. L. Cloud, President E. Dennison, Project Manager Teledyne Engineering Services (TES)

W. E. Cooper, Project Manager D. F. Landers, Vice President, Engineering R. Wray, Assistant Project Manager, Seismic G. Moy,'Princ_ipal Engineer and Manager C. G. Sprangers, Assistant Project Manager, QA *

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R. D. Foti, Manager, Projects R. D. Ciatto, Civil / Structural, Team Leader L. C. Noriega, Assistant Project Manager, Stone and Webster J. H. Malohson, TES Quality Assurance J. M. Cantalupo, Project Administrator

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R. R. Boentgen, Manager, Testing and Instrumentation

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R. C. Wilkinson, TES. West Coast Manager, Projects 2. Teledyne Engineering Services Hayward Facility

, An inspector visited the Teledyne Engineering Services (TES) Hayward

! office-on May 6, 1982 to verify the scope and purpose of that office's j

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involvement in the IDVP. Based on discussions with personnel and an examination of TES records the inspector concluded that the subject office did have personnel with mechanical and structural engineering expertise who would gather "as-built" data from the Diablo Canyon sit The inspector also concluded that this office would not become involved in the TES Technical Review ,

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3. Diablo Canyon Site Tour

. An inspector and the NRR Project Manager for the Independent Verification Program (IDVP) toured the Diablo Canyon site on May 10 and 11, 1982 to determine the status of PG&E modifications and to determine the involvement and awareness of on site personnel. The inspector determined that modifications to pipe and conduit / cable tray supports were largely complete and that on-site operations and construction personnel were appropriately knowledgeable of and involved with the IDVP. The inspector also observed that PG&E and Bechtel personnel were in the process of formulating their working relationships with the consolidated Bechtel/PG&E organizatio PG&E and R. L. Cloud and Associates Offices Two inspectors and the NRR Project Manager for the IDVP visited the PG&E and RLCA offices in San Francisco and Berkeley, respectively, during the period May 12-14, 1982 to verify adequate implementation of the IDVP plan and to review selected portions of the ongoing PG&E Technical (corrective) Programs. The inspectors examined the documents listed below:

PG&E Documents P-19, dated May 6, 1982 " Procedure for Reviewing as-built piping isometrics

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against seismic and thermal computer analyses" P-11, dated February 27, 1982 " Procedure for Seismic Analysis" C-17, dated April 19, 1982 Design Criteria Memorandum (Spectra for use in engineering analyses)

RLCA Documents

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QA Manual, dated March 22, 1982 Contract with PG&E, dated December 3, 1982 1 Diablo Canyon Independent Verification Program Project Specific Instructions, dated April 13, 1982 The inspectors also discussed the PG&E Technical Programs and calculations with PG&E and RLCA personne The inspectors observed that Procedure P-19 had different criteria

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for measurement tolerances than the IEB 79-14 walkdown tolerances contained in Procedure P-11. PG&E representatives stated that P-19 tolerances were used for engineering evaluations of deficiencies noted in the walkdowns. The inspectors requested that PG&E document the basis for the increased tolerances. PG&E representatives stated that they are currently revising the procedure, and would document the basis for any tolerance increases for the revised procedure.

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-3-The inspectors observed that the RLCA contract referenced the appropriate PG&E QA requirements. RLCA personnel stated that they were waiting for PG&E modifications before re-review of the main annunciator cabine RLCA personnel also stated that TES was in the process of auditing RLCA and that their QA program may be superceded by the TES QA progra . Teledyne Engineering Services Offices Two inspectors, the NRR Project Manager for the IDVP, and two technical reviewers from NRR visited the TES offices in Waltham, Massachusetts during the period May 25-26, 1982 to verify adequate implementation of the IDVP plan, to examine the independence and qualifications of TES personnel, and to verify adequacy and implementation of TES procedure The inspector examined the'following documents:

IDVP-PP-005, Rev. O draft, dated 4/5/82 " Potential or Apparent Conflicts of Interest of Individuals" IDVP-PP-003, Rev. O, dated 3/31/82 " Preparation of Open Item Reports, Error Reports, Program Resolution Reports, and IDVP Completion Reports" TES Letter dated 4/2/82, 5511-16, TES to PG&E Forwarding Program Management Plan TES Letter dated 4/14/82, 5511-26, TES to Stone & Webster, Roger F. Reedy

& RLCA IDVP-PP-004, Rev. O, dated 3/31/82 " Applicable Quality Assurance Requirements" TES QA Manual, March 21, 1980 and Project QA Program, project 5511, Rev. 3, dated 4/2/82 Roger F. Reedy, QA Manual, Edition 1, Rev. 0, dated 12/22/81 Project QA Program 5511, Rev. O, dated 1/8/82 PG&E Specification C0 Rev. 0, dated 11/10/81 - Teledyne " Specification for Consultants Quality Assurance Program" EP-1-013, Rev. O, dated 4/5/82, "DCNPP Individual, Design Verification Program - Program Management Plan" EP-1-014, Rev. O, dated 3/18/82 "TES Review and Evaluation Team Activities for DCNPP Design Verification Program" Special QA Procedure, SQAP-81-01, Rev. 0 " Control of Drawings, Specifications, Procedures and Instructions TEP-1-001, Rev. 2, dated 9/2/81 " Initiation Approval, Implementation, Revision, and Control of TES Procedures and Engineering Instructions" TEP-1-002, Rev. 2, dated 3/23/81 " Guidelines for Writing TES Engineering Procedures"

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-4-TEP-1-004, Rev. O, dated 9/8/81 " Reporting of 10 CFR 21 Offenses" TES QA Audit Summary for 5/17-18/1982 " Audit of Document Control upon Completion of Phase 0" PG&E letter to TES, dated 1/8/82, Agreement with TES for Design Reverification Program, Contract No. 5-2-82 April 20, 1982 TES visit to RLCA offices - Trip Report PG&E letter to-TES, dated 5/3/82, Approval of TES QA Program The inspectors also conducted interviews with TES personnel and discussed the application of TES procedures to the IDV A) Independence of Teledyne Engineering Services The inspectors reviewed the independence of the design verification contractor Teledyne Engineering Services (TES). The objective of the review was to ascertain whether the contractor could be expected to provide an objective, dispassionate technical judgment, provided solely on the basis of technical merit. The following factors were considered in this determination: The extent of the previous or current involvement of TES and the TES reviewers with Pacific Gas and Electric Company or Diablo Canyo Whether the TES reviewers or members of his or her immediate family own any beneficial interest in PG& Whether members of the immediate family of the TES reviewers are employed by PG& Information provided by TES to the NRC demonstrated that recent contracts between TES and PG&E account for only a small amount of TES revenue. The inspectors consider the value low enough to assure corporate financial independence.

i The inspectors consider that the TES individuals involved in l

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the IDVP demonstrate sufficient independence. This conclusion was based on review of twenty-four of the reviewers " Conflict of Interest" statements and confidential interviews with nine TES individuals. In all cases it was found that the individuals i

met the independence criteria established by the contracto In summary, for the reasons given above, the inspectors conclude that the selected contractor, TES, has adequately demonstrated both corporate and individual independence.

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-5-B) Implementation and Adequacy of Procedures The inspectors observed that the TES letter 5511-26, dated 4/14/82, made a minor revision to the NRC approved IDVP Plan. The inspectors

, stated that the NRC must be kept informed of all cha'nges to the plan and that NRC concurrence must be obtained prior to implementing procedures less conservative than the NRC approved IDVP. TES

representatives explained that the only change that they had made was to distribute copies of " Potential Program Resolution Reports" and " Potential Error Reports" to PG&E. TES representatives stated that they wou'd include this item in their next " Semi-

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Monthly Status Report" to document the change. The NRC inspectors

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stated that this was acceptabl The inspectors were informed by PG&E personnel present at TES offices that Paragraph 10.3 of the approved IDVP had been interpreted to allow calculations of frequencies cad made shapes of the Diablo Auxiliary Building to be transmitted to PG&E. The inspectors

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stated that PG&E and the IDVP members are free to discuss findings sufficiently to understand them, and that PG&E (or any party)

could send the IDVP members as much information as they wishe However, the inspectors stated, it was not appropriate to send copies of calculations, results of calculations, results of the IDVP or conclusions of the IDVP to PG&E prior to sending them to the NRC. The inspectors cautioned TES Personnel that even an appearance of influence must be avoided and that the exchange of data which PG&E personnel brought up should not be repeate During discussions to allow PG&E to understand the nature of

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IDVP findings a record should be kept (telephone memo, meeting

minutes, etc.) to document the exchange. TES representatives acknowledged the inspector's observations and stated that they i would submit an interpretation of paragraph 10.3 of the IDVP plan as soon as possible, keeping in mind the inspector's statements and the necessity of good communications. TES representatives diso stated that they were in the process of accumulating copies i

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of all the RLCA files to support the TES file item findings and disposition . Pacific Gas & Electric Offices One inspector visited the PG&E offices in San Francisco during the e

period May 25-28, 1982 to examine the findings of the Blume Internal Review Committee and to check the status of ongoing civil / structural work. The inspector discussed these items with PG&E and Bechtel personnel assigned to the Diablo Canyon Projec ..

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i -6-The inspector observed that there is no simple way to cross a specific

spectra to items for which it is relevent. The inspector also observed j that equations 3 and 4 of the Civil Design Criteria Memo (DCM) require

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clarifications and that item TB001 (Turbine Building Ductibility" may be required for submittal to the NRC. PG&E representatives acknowledged the inspectors observations and stated that equations 3 and 4 of the

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j DCM would be changed to clarify the use of an absolute su . Exit Interview At the conclusion of each segment (by dates and locations) of the inspection the inspectors met with appropriate representatives of

the entities inspected to explain the scope and findings of the inspection.

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